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6, 1985). Thus, section 274(d) overrides Cohan v. Commissioner,
39 F.2d 540, 543-544 (2d Cir. 1930), which allows the Court, in
some circumstances, to estimate a deductible expense. See
Sanford v. Commissioner, 50 T.C. 823, 827 (1968), affd. per
curiam 412 F.2d 201 (2d Cir. 1969); sec. 1.274-5T(a), Temporary
Income Tax Regs., supra.
Although petitioner offered into evidence numerous receipts
in support of his travel, meals, and entertainment expenses, he
did not provide the additional documentation necessary to
substantiate these expenses. In particular, the receipts did not
show the business purpose behind the trips or meals. In short,
there was no documentation or rationale behind such expenses
other than petitioner’s unsupported testimony that the Court
declines to accept. Sec. 1.274-5T(a), Temporary Income Tax
Regs., supra. Respondent is sustained on this issue.
On a separate Schedule C of petitioner’s 2000 income tax
return, petitioner claimed a deduction for expenses relating to
another activity called “Frexie”. This was the name petitioner
ascribed to his purchase of the right to use a luxury suite at
Minute Maid Park in Houston, Texas, the home field for the
Houston Astros major league baseball team, for a 3-year period
for $250,000. The Frexie activity involved the selling or
letting by petitioner of the use of the suite during Houston
Astros baseball games. In exchange for a commitment to purchase
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